Reasons for Decision
1
income years ending 30 June 2006 and earlier, a UK LLP was not a foreign hybrid company for the purposes of section 830-15 of Division 830 of the ITAA 1997; and 2. income years beginning on or after 1 July 2006, a UK LLP will be a foreign hybrid company for the purposes of section 830-15 provided that it also meets the assumed remaining requirements of subsection 830-15(1) of the ITAA 1997.